UNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF NEW YORK ARISTA RECORDS LLC; ATLANTIC RECORDING CORPORATION; ARISTA MUSIC, fka BMG MUSIC; CAPITOL RECORDS, LLC, fka CAPITOL RECORDS, INC.; ELEKTRA ENTERTAINMENT GROUP INC.; INTERSCOPE RECORDS; LAFACE RECORDS LLC; MOTOWN RECORD COMPANY, L.P.; PRIORITY RECORDS LLC; SONY MUSIC ENTERTAINMENT, fka SONY BMG MUSIC ENTERTAINMENT; UMG RECORDINGS, INC.; VIRGIN RECORDS AMERICA, INC.; and WARNER BROS. RECORDS INC., Plaintiffs, v. LIME WIRE LLC; LIME GROUP LLC; MARK GORTON; and M.J.G. LIME WIRE FAMILY LIMITED PARTNERSHIP, Defendants. PLAINTIFFS' NOTICE OF MOTIONS AND PLAINTIFFS' MOTIONS IN LIMINE TO PRECLUDE SPECIFIED CATEGORIES OF EVIDENCE AND ARGUMENT
06 Civ. 05936 (KMW) ECF CASE
Glenn D. Pomerantz (pro hac vice) Kelly M. Klaus (pro hac vice) Melinda E. LeMoine Susan T. Boyd (pro hac vice) Jonathan H. Blavin (pro hac vice) Munger, Tolles & Olson LLP 355 South Grand Avenue Los Angeles, CA 90071 (213) 683-9100 Attorneys for Plaintiffs Date: February 25, 2011
TO ALL PARTIES AND THEIR ATTORNEYS OF RECORD: PLEASE TAKE NOTICE that as soon as counsel may be heard before the Honorable Kimba M. Wood in Courtroom 15B, United States Courthouse, 500 Pearl Street, New York, New York, all Plaintiffs in Case No. 06 Civ. 05936 ("Plaintiffs") will and hereby do move the Court pursuant to the Federal Rules of Evidence, this Court's Orders, and the Local Rules of the Southern District of New York, for the following relief: Plaintiffs' Motion In Limine to Preclude Evidence or Argument Concerning Prior Settlement Discussions Plaintiffs' Motion In Limine To Preclude Evidence Or Argument Inconsistent With Facts Established At Summary Judgment Plaintiffs' Motion In Limine to Preclude Defendants' Argument That Other Illegal Services Would Have Induced Infringement Of Plaintiffs' Copyrights If Lime Wire Had Not Plaintiffs Motion In Limine to Preclude Defendants From Asserting Privilege Over Communications With Fred Von Lohmann Or The Electronic Frontier Foundation Plaintiffs' Motion In Limine to Preclude any Argument or Evidence Concerning Defendants' Purported Belief in the Lawfulness of their Conduct PLEASE TAKE FURTHER NOTICE that these Motions are based on this Notice of Motions, Motions, the accompanying Memoranda of Law, the Declarations of Melinda E. // // //
LeMoine, Susan Traub Boyd, and Kelly M. Klaus along with all accompanying evidence attached and cited therein, any Reply Memorandum in support, the court records and files, and upon such other evidence and argument that may be offered at the hearing on the Motion. Dated: February 25, 2011 Respectfully submitted /s/ Melinda E. LeMoine Melinda E. LeMoine Attorney for Plaintiffs Munger, Tolles & Olson LLP 355 South Grand Avenue, 35th Floor Los Angeles, CA 90071-1560 (213) 683-9100 (213) 687-3702 (Fax)

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